Seth Shapiro v. AT&T Mobility, LLC

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IN THE UNITED STATES DISTRICT COURT

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FOR THE CENTRAL DISTRICT OF CALIFORNIA

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4 SETH SHAPIRO, Cas e No. 2:19-cv-08972-CBM (RAOx) 5 Plaintiff, STIPULATION AND PROPOSED 6 vs. PROTECTIVE ORDER 7 AT&T MOBILITY, LLC, et al., 8

9 Defendants. 10 11 12 1. PURPOSES AND LIMITATIONS 13 Discovery in this action is likely to involve production of confidential, 14 proprietary or private information for which special protection from public 15 disclosure and from use for any purpose other than pursuing this litigation may be 16 warranted. Accordingly, the parties hereby stipulate to and petition the Court to enter 17 the following Stipulated Protective Order. The parties acknowledge that this Order 18 does not confer blanket protections on all disclosures or responses to discovery and 19 that the protection it affords from public disclosure and use extends only to the 20 limited information or items that are entitled to confidential treatment under the 21 applicable legal principles. 22 2. GOOD CAUSE STATEMENT 23 This action is likely to involve trade secrets,…